Secretary of Education Arne Duncan recently unveiled the Obama Administration’s proposal — or “Blueprint” — for the re-authorization of the Elementary and Secondary Education Act, the controversial law more commonly known as “No Child Left Behind.” For teachers, students and families, re-authorization is a long-awaited opportunity to correct the failings of the existing policy, which purported to help disadvantaged students achieve proficiency in math and reading but has led to an excessive focus on standardized tests, a narrowing of the curriculum, and cynicism on the part of educators who have pretended to meet impossible goals. Now, when the country’s education system has an important window to undo flawed policies of the past, we should proceed carefully to avoid another hastily designed law where unintended consequences undermine good intentions. Yet the Administration’s proposal fails in this respect; if enacted, the “Blueprint” would perpetuate the problems it claims to correct in American education.

The Administration’s education policy feints in several positive directions. It hopes to inspire more young people to go to college, but recognizes that college is becoming prohibitively expensive for low- and middle-income families. So the budget reconciliation bill took back the college loan program from inefficient private lenders. The more than $60 billion in additional grants that will result — from eliminating bankers’ fees for issuing government-insured loans — will enable about 8 million students to attend college who might otherwise not be able to do so. It would be foolish to try to re-organize elementary and secondary education to make students “college-ready” if college itself becomes less affordable.

In another positive move, the stimulus bill of February 2009 filled holes in state education budgets, avoiding the need for states to layoff perhaps a third of a million teachers and other school employees. Yet the college loan and stimulus measures, while steps in the right direction, are inadequate. College costs are far outpacing the added financial help provided by a more efficient college loan program. California and Georgia, for example, recently announced tuition increases of over 30%. And one-time stimulus money cannot prevent growing layoffs of teachers and other school employees, resulting in increased class sizes and less ability for states to provide other programs that the Administration desires — such as more access to advanced placement classes for disadvantaged students and a broader curriculum that goes beyond math and reading. The economic crisis of public education will only get worse

— many states fund public education in part by property taxes, and with real estate values low, layoffs of educators will intensify as reduced tax collections work their way through state and local budgets. Many school districts anticipate that budgets may not recover until Fiscal Year 2013, or perhaps later.

Blueprint has some worthy goals
The Administration’s Blueprint for re-authorization of the Elementary and Secondary Education Act (ESEA) also reflects some positive goals. Recognizing that the existing ESEA (No Child Left Behind, or NCLB) has narrowed the curriculum, the Administration proposes funding some states to broaden their curricula to include elements of “a well-rounded education [to give students the capacity] to contribute as citizens in our democracy and to thrive in a global economy — from literacy to mathematics, science, and technology to history, civics, foreign languages, the arts, financial literacy, and other subjects.”

The Blueprint also recognizes that student success cannot depend on the regular school day alone, and so proposes to fund some states that improve “early learning outcomes,” that provide before-, after-school and summer programs, that provide “comprehensive supports to students and families through full-service community school models,” and that develop “Promise Neighborhoods” projects that implement “a continuum of effective community services, strong family supports, and comprehensive education reforms to improve the educational and life outcomes for children and youths in high-need communities, from birth through college and into careers.”

Competitive grants make no sense in budget crises
Yet these positive steps seem somewhat inconsistent with other aspects of the Blueprint and associated budget recommendations. Perhaps most troubling are the Blueprint’s extensive proposals to use ESEA funds for competitive grants to fund some states’ implementation of the policies described above. These might not be problematic if the competitive grants were being funded in normal economic times, with dollars supplementary to regular formula funding (where states get compensatory education — “Title I” — funds on a per child basis). But in the present period, with extensive layoffs of teachers and other school employees looming, it makes no sense to cut (in real, inflation adjusted terms) formula-driven funds in order to reward states that innovate in ways that suit the Administration’s policy preferences. A full employment program for grant-writers is no substitute for stable employment for educators. And what are states that don’t win the competitive grants, and thus have no way to avoid the layoffs, to do?

The practical reality is that in any economic climate, but especially the present one, no Congressman is going to allow schools in his or her district to layoff teachers so that other districts can get competitive funding. The result will be money spread around a little more evenly, but in a more haphazard way than Title I formula funds. A lot of money will be wasted on grant-writing and evaluation when it could have been spent on real educational services. And with political pressure as well as (if not more than) proposal quality determining the awards, little policy innovation will be accomplished.

Curriculum narrowing and gaming will continue with middle-class schools exempt
In some disturbing ways, the Blueprint continues core NCLB policies that the competitive grants purport to correct. The most important is the accountability system. NCLB did the most harm by placing such high stakes on annual tests of math and reading that it created incentives for schools to narrow the curriculum and to substitute gaming for education. The narrowing was both inter-subject and intra-subject. Inter-subject narrowing consisted of reducing time and attention paid to the arts, science, history, physical education and other non-tested subjects. Intra-subject narrowing consisted of overemphasizing the basic skills most likely to be tested, and ignoring more difficult-to-test aspects of the math and reading curriculum, such as mathematical reasoning, critical thinking, and appreciation of good literature. Both types of narrowing disproportionately occurred in schools serving disadvantaged children, for these were the schools most in danger of suffering sanctions for low test scores.

NCLB also created incentives for other gaming. The most notorious was the targeting of students whose basic skills performance fell just short of “proficient.” Schools could increase their ratings, and escape sanctions, by improving the scores of a small number of students just below this criterion, and ignoring both students who were far behind (and had no chance of passing the proficiency point) and those who were already proficient.

The Blueprint continues this system, although with a twist. Only the bottom 5 percent of schools (called “Challenge” schools) will suffer severe sanctions (such as firing or replacing the staff) as a result of low test scores. Although all schools will be required to continue to administer annual math and reading tests alone, the Administration suggests that the absence of sanctions for the top 95 percent of schools will give states the flexibility to design new accountability systems that may even include requiring schools to broaden their curricula.

The next-lowest 5 percent of schools will be placed on “Warning” status; these schools, too, will have all the perverse incentives of the Challenge schools. Still, though, this presumably leaves 90 percent of schools with the flexibility to broaden their curricula and avoid excessive test-prep activities and gaming.

But not really. What Blueprint enthusiasts have neglected to recognize is that the tests of math and reading have always been highly unreliable. If we consider, say, the bottom 20 percent of schools, it is only a matter of chance whether a school will test low enough in any year to be categorized as Challenged. Schools that are Challenged in one year have a high probability of being in a safer category the next, and vice-versa.

The result of all this is that schools serving a large proportion of minority students will behave under the Blueprint very similarly to how they behaved under NCLB. If the Administration succeeds in raising the proficiency cut points (now called “college and career ready” standards), even more students will be ignored because they are too far below the passing point to matter.

Schools with largely middle class populations will effectively be exempt. The political consequences of this could be dangerous: federal officials will no longer be besieged by middle class parents upset that their schools have turned into test-prep factories; only poor and minority communities will suffer the punitive hammer of federal policy.

Recognizing the impact of economic stress on achievement
The Blueprint’s accountability provisions are also curiously contradictory. The Administration proposes competitive grants to establish Promise Neighborhoods that coordinate a wide range of social, health, and community services with schools, and will reward states with funds to establish programs that nurture children from birth and serve disadvantaged children’s before, after-school, and summer needs. A reasonable inference is that the Administration believes (correctly) that such programs contribute to student achievement. As Secretary of Education Arne Duncan has stated: “It takes more than a school to educate a student. It takes a city that can provide support from the parks department, health services, law enforcement, social services, after-school programs, nonprofits, businesses, and churches.”

If this is the case, however, whether a school is “Challenged” or on “Warning” status depends not only on the quality of its instruction, but on whether its students come to school ready to learn, with the benefits of Promise-Neighborhoodstype services. Imagine two schools of equal quality. Test scores in the first may be higher because its students come to school after enrollment in high quality early childhood programs and from the cooperative support of the parks department, health services, law enforcement, social services, after-school programs, nonprofits, businesses, and churches. Test scores in the second may be lower solely because of the absence of these supports. The Blueprint proposes to transform the second school by replacing the principal and teachers, turning the school over to private management or other draconian measures. It would be more logical to leave the instructional staff intact (after all, an instructional staff of identical quality is able to get satisfactory results in the first school) and instead remedy the situation by providing the early childhood, after school, health and other services that produce higher achievement.

If the Blueprint is politically tone-deaf with regards to the feasibility of shifting formula funds to competitive grants in a deep economic recession, it is sociologically tone-deaf with regards to the goal of raising achievement goals in this period. Presently, a quarter of black young and middle-aged adults, of an age to have children in school, are either unemployed, or so discouraged about looking for work that they have dropped out of the labor force. During the course of the year, approximately 40 percent of black adults will be unemployed at one time or another. Schoolchildren from families in such circumstances will change schools more often because of housing instability, will more frequently come to school hungry, in poor health, and with behavioral problems arising from family stress. It would be a remarkable accomplishment for the achievement of disadvantaged children to remain stable for the duration of the economic crisis. Expectations of near-term improvement are breathtakingly removed from reality.

Growth can’t reasonably be measured
The Blueprint refers repeatedly to the desirability of (and presumably, in Challenge schools, the requirement for) measurement of “growth” in math and reading scores. Not only are principals and teachers to be evaluated, and teacher compensation systems to be redesigned to account for the “growth” of students, but even teacher training institutions are to be judged by their contribution to such “growth.” Sanctions for the lowest-performing schools, and also the award of competitive grants, depend on such measurement. We can assume that, to measure growth, the Blueprint does not envision requiring schools now to test math and reading twice yearly, once in September and again in June. But if not, it is hard to imagine how states are going to respond to this demand for growth measurement. NCLB insisted that annual tests must be given early enough in the year so that they could be scored in time to design interventions for the next school year. The Blueprint will need a similar requirement if Challenge schools are going to be “turned around” the following year. Yet if tests are given, say, in March, which teachers are to get credit for students’ gains, or lack of them

— the teacher who had the students from September to March, or the teacher who had the students from the previous March to the previous June? And how can such “growth” models account for learning, or lack of it, that takes place during the summer? One recent analysis calculated that over half of the schools in the lowest quintile of performance are mistakenly assigned to this low-performance category solely because of differences in children’s summer learning — or lack of it. Perhaps in the future we will develop a way around these problems, but we have not found one to date, and it seems precipitous for the Administration — especially one that claims to be committed to research and evidence-based policy — to load so many incentives onto a statistical technology for which there is no present prospect.

How equal is “comparable?”
Other Blueprint proposals also seem to have been poorly (or too hurriedly) thought-through. One that has received relatively little attention is a requirement for intra-district funding equalization: “Over time, districts will be required to ensure that their high-poverty schools receive state and local funding levels (for personnel and relevant non-personnel expenditures) comparable to those received by their low-poverty schools.” Surely the Administration must be aware that there is now a 40-year tangle of litigation i
n a majority of states that attempts to define precisely what finance equalization means. Does “comparable” mean that high-poverty schools (however they are defined) should receive the same per-pupil resources as low-poverty schools, or does comparability require an adjustment for the greater needs of students in high-poverty schools? If the latter, how much of an adjustment?

Further, the most important cause of intra-district funding inequality is the tendency in some places for teachers serving low-income children to have less seniority, on average, than teachers serving middle-class children. As a result, total salaries paid to teachers in high-poverty schools may be less than the total paid to the same number of teachers in low-poverty schools. A requirement for equalization is, in effect, a requirement that more senior, higher-salaried teachers be re-assigned from low-poverty to high-poverty schools. The Blueprint calls for re-assigning the most effective teachers to high-poverty schools where “they are needed the most.” A fiscal requirement that more senior teachers be re-assigned to high-poverty schools seriously limits the ability of districts to make assignments based on other criteria of effectiveness. Many influential policy advocates have argued that seniority has little to do with effectiveness, and have promoted programs that recruit young college graduates for brief stints as teachers — Teach for America being the best known of these. The Blueprint endorses such programs, saying that priority for winning competitive grants “may be given to programs that work to recruit and prepare high-performing college graduates or non-traditional candidates, such as military veterans or midcareer professionals” for high-needs schools and students. Such teacher recruits will necessarily start at the bottom of the salary schedule. It is hard to imagine how such a priority can be fulfilled at the same time that districts must transfer senior teachers to ensure that funding levels in high-poverty and low-poverty schools are comparable.

Utopian goals — and cynicism — continue
The Blueprint’s overall theme is that by 2020 all students should graduate from high school “College and Career Ready.” Administration officials have explained that this entails the ability to gain admission to an academic college program without having to take remedial courses. (The addition of “Career” to “College Ready” is meaningless, because what the Administration intends to convey is that some students may choose to pursue a non-college career, but would still have gained the qualifications to enter an academic college program if they wished.) This is, perhaps, the most disturbing aspect of the Blueprint. It indicates that the Administration may have learned little from the NCLB experience.

The most widely ridiculed of NCLB’s pretensions was that all students would be “proficient” at a challenging standard by 2014. Arne Duncan has called this goal “utopian” and nobody seriously thinks that the goal ever was achievable, or close to achievable. The normal variability of human ability ensures that no standard of proficiency can simultaneously be “challenging” for students at the top and the bottom of the normal ability distribution.

But aside from ridicule, NCLB’s adoption of this goal did great harm to public education. It created incentives for educators to lie to the public and claim that they could achieve something that they knew was unachievable. It created well-known incentives to “define down” proficiency, to make it possible for more students to pass themselves off as proficient. It engendered a culture of cynicism in public education, and it discredited public education in the broader community, as it became apparent that school leaders could not deliver what they were promising. Any institution that sets an impossible goal runs the risk of such cynicism and loss of legitimacy.

The goal of all students college-ready by 2020 is just as fanciful as the goal of all students proficient by 2014. Today, perhaps 20 percent of all youth graduate high school fully prepared for academic college. It should certainly be higher. Aspiring to make it higher is a worthy ambition. But basing policy on a promise, or even an expectation, that we will quintuple this rate in a mere decade is laughable.

Administration officials defend this goal by saying it is “aspirational,” unlike NCLB’s goal which was a mandate. As we have seen above, this is not accurate. Virtually all schools serving concentrations of disadvantaged children will be in danger of sanctions for failing to make progress towards this goal. For these schools, the same cynicism, the same false promises, the same gaming, will be stimulated as occurred with NCLB.

Even middle class schools will be harmed by this goal. Although they will not be closed or otherwise sanctioned for failing to have all students college-ready by 2020, they will still regularly have to report to the public that their performance is inadequate, regardless of its actual quality. In these cases, we can foresee the consequences. Just as it was easy to make most students proficient by making the definition of proficiency sufficiently minimal, so we can expect states (that control both higher and K-12 education systems) to start defining college readiness down. Promising to make all students college-ready by 2020 is, in effect, an attack on the quality of America’s institutions of higher education.

Defenders of this absurd goal aver that it is inspiring to have an aspirational goal, even if it cannot be met. This is true only if the goal is within reach, albeit with great effort. If the goal is entirely out of reach, then holding it up as an aspiration is corrupting.

Of course, every teacher should attempt to inspire every entering kindergartner, as that child proceeds through school, with encouragement that greater effort could lead to college and a professional career. But no sane teacher believes that this encouragement will be effective with every single child. When an /institution promises such universal success, it undermines its own legitimacy.

Back to the drawing board
We can hope that the Administration thinks further about its proposals, and revises them as they proceed through Congress. It is, in any event, virtually certain that the Blueprint will not be adopted in its present design by this Congress, and perhaps not even by the next.

This suggests an unintended benefit of the Blueprint. For the foreseeable future, Arne Duncan will continue to be responsible for administering NCLB. Having now gone on record that its provisions are seriously flawed and that compliance with them is doing American education great harm, the Secretary will have no coherent choice but to begin issuing wholesale waivers to states from compliance with the old law. If it accomplishes this much, the Blueprint will have done a great service.

(An earlier version of this analysis was also posted on the education discussion site of the National Journal.)